Canara Bank v. JCIT

60 ITR (Trib) 1Income Tax Appellate Tribunal2017#2487 most cited

What is Canara Bank v. JCIT authority for?

For banks, the computation of bad debt allowance under sections 36(1)(vii) or 36(1)(viia) must be restricted to only incremental advances, rejecting broader interpretations by tax authorities.

47

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2018 to 2025.

Also referred to as

Canara Bank v. JCIT · bad debt allowance for banks · section 36(1)(vii) · section 36(1)(viia) · incremental advances computation · provision for bad and doubtful debts · bank income tax deductions · ITAT Bangalore

Issues it is cited on

Judgments citing Canara Bank v. JCIT

ACIT Circle 3, Lucknow vs. Rajdhani Nagar Sahkari Bank Ltd, Lucknow

In the result, the appeal of the assessee in ITA

ITA 141/LKW/2024[2016-17]Status: DisposedITAT Lucknow22 May 2025AY 2016-17

Bench: Shri Kul Bharat & Before Shri Kul Bharat & Before Shri Kul Bharat & Shri Nikhil Choudharyshri Nikhil Choudharyshri Nikhil Choudharyita Nos. 112 To 114/Lkw/2024 A.Ys. 2015-16 To 2017-18 Rajdhani Nagar Sahkari Rajdhani Nagar Sahkari Vs. Dcit Bank Ltd P.K. Complex, Raja Ram Mohan P.K. Complex, Raja Ram Mohan 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Rai Marg, Lucknow-226001. 226001. Alambagh, Lucknow-226006 226006 Pan:Aaaar1269D (Appellant) (Respondent) (Respondent) A.Y.2016-17 Acit Circle-3 Vs. Rajdhani Nagar Sahkari Bank Rajdhani Nagar Sahkari Bank 57 Ram Tirath Marg Pratyaksh 57 Ram Tirath Marg Pratyaksh Ltd Kar Bhawan, Lucknow Kar Bhawan, Lucknow-226001 555Ga/86, Sardari Khera, 555Ga/86, Sardari Khera, Alambagh, Lucknow-226006 226006 Pan: Aaaar1269D (Appellant) (Respondent) (Respondent) Assessee By: Sh. K.R. Rastogi, C.A. Sh. Shubham Rastogi, C.A. Revenue By: Sh. Sanjeev Krishna Sharma, Addl. Addl. Cit- Dr Date Of Hearing: 28.04.2025 Date Of Pronouncement: Date Of Pronouncement: 22.05.2025 O R D E R Per Bench.: These Four Appeals Have Been Have Been Filed For The Assessment Years 2015 For The Assessment Years 2015-16, 2016- 17 & 2017-18 By The Assessee & Revenue Ssessee & Revenue Against The Respective Orders Of The Respective Orders Of The Ld. Cit(A)/Nfac, Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024. While The Delhi Dated 02.02.2024, 05.02.2024 & 05.02.2024 Assessee Is In Appeal In Assessment Years 2015 Assessee Is In Appeal In Assessment Years 2015-16, 2016-17 & 2017-18, The Revenue 18, The Revenue

For Appellant: Sh. K.R. Rastogi, C.AFor Respondent: Sh. Sanjeev Krishna Sharma, Addl
Section 36(1)(v)

…nd placed reliance on the decision of Hon'ble Karnataka High Court in the case of CIT & anr vs ING VYSYA Bank Limited 186 DTR 193. Other cases, on which reliance were placed were the decisions of the Bangalore Tribunal in the case of Canara Bank vs CIT (2016) 68 Taxmann.com 128 (Bang Trib) and Capital Local Area Bank Ltd vs ACIT (2017) 82 taxmann.com 387 (Amritsar Trib). On the deletion of Rs.2,23,54,660/- by the Ld. CIT(A), which had been raised by the Revenue in ITA. No.141/LKW/2024, it was submitted that the assessee bank had never claimed exemption u/s 2(15) of the Act and the only adjustment made to the prof…

Lalita Ramniranjan Agarwal, Vadodara vs. The Income Tax Officer, Ward-1(2)(4), Vadodara

In the result, the appeal filed by the Assessee is allowed

ITA 662/AHD/2023[2015-16]Status: DisposedITAT Ahmedabad28 Feb 2025AY 2015-16

Bench: Shri TR Senthil Kumar, Judicial Member\nAnd Shri Narendra Prasad Sinha, Accountant Member\nITA No. 662/Ahd/2023\nAssessment Year 2015-16\nLalita Ramniranjan Agarwal,\nB-201, Sandal Wood\nResidency, Urmi Char Rasta\nProductivity Road,\nVadodara-390020\nPAN: AECPA0173J\n(Appellant)\nThe ITO,\nWard-1(2)(4),\nVadodara\nVs\n(Respondent)\nAssessee by: Shri P.M. Jagasheth, A.R.\nRevenue by: Shri Nitin Vishnu Kulkarni, Sr. D.R.\nDate of hearing\n: 24-02-2025\nDate of pronouncement : 28-02-2025\nORD

For Appellant: Shri P.M. Jagasheth, A.RFor Respondent: Shri Nitin Vishnu Kulkarni, Sr. D.R
Section 10(38)Section 143(1)Section 143(3)Section 68

…o-ordinate bench's decision in ITA_No. 1918/Kol/2018 in Smt. Sangita Jhunjhunwala vs. ITO decided on 04.01.2019 has deleted similar bogus LTCG vide following detailed discussion in para 3 to 5 as under... Para 8 "This tribunal's yet another decision in (2017) 60 ITR (Trib) 1 (Bang) Canara Bank vs. JCIT holds that the estopple principle does not apply in income tax proceedings. We therefore reject Revenue's arguments in support of impugned addition. We take into account all the relevant facts and circumstances to adopt the learned co-ordinate bench's above extracted detailed reasoning mutatis mutandis to delete th…

Karnataka Bank Ltd, Mangaluru vs. Deputy Commissioner of Income Tax, Mangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 875/BANG/2023[2008-09]Status: DisposedITAT Bangalore01 Feb 2024AY 2008-09

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2008-09 Karnataka Bank Ltd. Near Mahaveer Circle Pumpwell Kankanady Vs. Mangaluru Dcit Karnataka 575 002 Mangalore Pan No.Aabct5589K Assessee Respondent Assessee By : Sri Ananthan S. & Smt. Lalitha Rameswaran, A.Rs Revenue By : Ms. Neera Malhotra, D.R. Date Of Hearing : 08.02.2024 Date Of Pronouncement : 08.02.2024 O R D E R Per Chandra Poojari: This Appeal By Assessee Is Directed Against Order Of Nfac For The Assessment Year 2008-09 Dated 27.9.2023. The Assessee Has Raised Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income Tax (A) Is Bad Is Law & Against The Facts Of The Case. 2. The Learned Commissioner Of Income Tax (A) Erred In Remanding The Issue Back To The Ao For Verification. 2.1. The Learned Commissioner Of Income Tax, Having Observed In His Order That All The Details Required To Comply With The Directions Of Itat Has Been Furnished By The Assessee Bank, Ought Not Have Remanded Back The Issue Again To Ao For Verification, Instead Of Allowing The Appeal In Favor Of The Assessee Bank. 2.2 The Learned Commissioner Of Income Tax (A) Erred In Not Deleting The Disallowance Made By The Learned Assessing Officer.: Karnataka Bank Ltd., Mangaluru Page 2 Of 6 3. The Learned Commissioner Of Income Tax (A) Failed To Appreciate The Fact That The Order Of The Learned Assessing Officer Is Beyond The Directions Given By The Hon'Ble

For Appellant: Sri Ananthan S. & Smt. Lalitha RameswaranFor Respondent: Ms. Neera Malhotra, D.R
Section 143(3)Section 36(1)(vii)

…ITA No.875/Bang/2023 Karnataka Bank Ltd., Mangaluru IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH: BANGALORE BEFORE SHRI GEORGE GEORGE K., VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER Assessment Year: 2008-09 Karnataka Bank Ltd. Near Mahaveer Circle Pumpwell Kankanady Vs. Mangaluru DCIT Karnataka 575 002 Mangalore PAN NO.AABCT5589K ASSESSEE RESPONDENT Assessee by : Sri Ananthan S. & Smt. Lalitha Rameswaran, A.Rs Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 08.02.2024 Date of Pronouncement : 08.02.2024 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: This appeal by assessee is direct…

Canara Bank v. JCIT (60 ITR (Trib) 1) — Cited in 47 Judgments | BharatTax